June 2018 “School’s Out” E-rate Update

June 5, 2018

Summer has unofficially begun!  E-rate never takes a vacation, so please take a minute and review these E-rate updates as you head to the beach or pack the camper.

• Sign PEPPM LOA if You Haven’t Already – https://www.peppm.org/ErateLOA – The FCC’s 2014 E-rate Modernization Order included a new provision requiring all consortia leads to obtain a signed LOA (Letter of Agency) from their participating members before the Form 470 is posted.  The current PA PEPPM Contract is being rebid starting in July 2018, so we need all entities that may wish to use the PEPPM contract for E-rate purchases in the next 3 years to complete an online PEPPM LOA to be included in the initial procurement.  If an entity does not complete the PEPPM LOA by the deadline, they will not be permitted to conduct a PEPPM mini-bid and cite the PEPPM contract on a future Form 471.  By signing this LOA, you are not obligating yourself whatsoever to purchase from the PEPPM contract.  You are merely stating that you are allowing the PEPPM administrators to include you as an eligible entity on the Form 470.  Therefore, I STRONGLY encourage all PA public schools to sign the LOA to give yourself as many bidding options as possible should you choose to use the E-rate Category 2 funding in the future.  Although nonpublic schools and libraries typically do not use the PEPPM contract for their E-rate purchases because they don’t have state law bidding restrictions, they are welcome to complete the online PEPPM LOA to given themselves the option to conduct a PEPPM mini-bid in the future.  The online LOA is very simple to complete and should take about 15 seconds.  You do not need to print, sign and mail the LOA — the online submission is sufficient.  https://www.peppm.org/ErateLOA

• FY 2018 Funding Commitments:  FY 2018 funding is being committed at a rapid pace this year, with 84% of PA’s funding requests having been decided thus far.  If you’d haven’t yet been funded but would like to know what stage of review your application resides, > Log into EPC Landing Page > Search for your Form 471 at the bottom of the page > Click on the Form 471 Application Number > Look at the top of the page for the 471 Status Bar.  If you need assistance with understanding the overall PIA review process, please see:  https://e-ratepa.org/?p=25321.  If you need assistance with responding to a PIA inquiry, please e-mail me!

• Denials:  Luckily, only a handful of FRNs have been denied so far this year, but if your FRN has been denied (and it’s not due to the phase out of voice), please consider appealing.  Most denials are related to the applicant not responding to PIA requests, or reducing their C2 requests to meet the available C2 budgets.  Both of these reasons can be overturned on appeal!  Appeals are due to USAC within 60 calendar days of the FCDL date.  If you need assistance is crafting your appeal, please contact me.

• Remember to File Your Form 486:  The next step after receiving a FCDL (funding commitment decision letter) is to file the Form 486. It’s a very easy form to submit and I strongly encourage you to file it on the day you receive the FCDL so you don’t forget.  Two reminders:  Check the ‘Early Filing Box’ if filing the 486 before July 31, and be careful not to be “click happy” on the CIPA certifications.  Full instructions on the Form 486 can be found at:  https://e-ratepa.org/?p=25591.

• Purchasing Category 2 Equipment Now:  Applicants are allowed to purchase their C2 equipment now, even if they haven’t yet received their FCDLs, because E-rate rules permit the purchase/installation of equipment after April 1 (3 months ahead of the start of the funding year).  Vendor invoices to schools/libraries are permitted to be dated on or after April 1, but BEARs or vendor SPIs cannot be submitted to USAC for reimbursement until July 1 (or the FCDL/486 submission date, whichever is later).  If you do purchase equipment before receiving the FCDL, know that vendors may want you to pay 100% of the cost and then seek reimbursement from USAC via the BEAR.   When purchasing C2 equipment, please review these purchasing/documentation guidelines:  https://e-ratepa.org/?p=25401.

• Changing 471 Contacts:  If you have a new staff member handing E-rate for your school or library – one that is different than the name listed on the 471 – please submit a RAL Modification in EPC at to make this change so the PIA reviewer knows where to send the PIA inquiry.  For help with RAL Modifications, see: https://e-ratepa.org/?p=25111.  You’ll also need to your EPC Account Administrator (AA) to create a new EPC user account for the additional E-rate contact.  If the AA is the new staff member, contact CSB and they will assist you with creating a new EPC AA account.  Please contact me if you need assistance creating a new EPC User Account.  Also, if you need any new E-rate contact added to the PA E-rate Listserve, please send me their contact information!

• Don’t Forget to Cancel Expiring Contracts:  If you are changing service providers beginning July 1, 2018 or no longer need a particular service, don’t forget to notify your existing vendor in writing that your service will be terminating on June 30.  Many contracts, even if they contain an expiration date, require that notice must be provided X number of days in advance or the contract will continue for another year.  You don’t want to be caught having to pay for service you don’t want simply because you forgot to give the required notice.

• BEAR Reimbursement Filings:  Starting July 1, 2018, applicants can begin to submit BEARs for FY 2018 equipment purchases that were made after April 1.  This is also about the time when applicants who did not receive discounted vendor bills for FY 2017 will begin to submit those BEARs as well.  I’ll provide more detailed information on filing that form in the coming weeks, but I wanted you to be aware that this date is approaching.

If you have any questions, please don’t hesitate to contact me at jtschell@comcast.net.

Happy Summer, E-raters!

— Julie

Julie Tritt Schell
PA E-rate Coordinator

717-730-7133 – o
717-730-9060 – f
jtschell@comcast.net
www.e-ratepa.org